State of Indiana v. David Brown, 2017 Ind. LEXIS 169

In July 2013 Indianapolis police ran a public sobriety checkpoint in a well-lit Arby’s parking lot; officers had a two‑minute limit per motorist to assess impairment.
David Brown, on a motorcycle, was stopped; Officer Winter noticed signs of intoxication, asked if Brown had been drinking, and Brown admitted he had been; field sobriety tests and arrest followed.
At bench trial, an officer testified Brown admitted drinking; defense counsel objected, arguing no Miranda warnings were given before the admission.
The trial court granted Brown’s motion to suppress “any statements by [Brown], as well as any evidence obtained thereafter,” excluding the admission and subsequent evidence; the State appealed.
The Court of Appeals dismissed the State’s appeal on procedural grounds; the State petitioned for transfer to the Indiana Supreme Court, which accepted the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May the State appeal the trial court’s suppression order?	State: Yes under Ind. Code § 35‑38‑4‑2(5) because the order granted a motion to suppress and effectively precludes prosecution.	Brown: Procedural defects (no written motion to suppress; order issued during trial) bar appeal.	Yes. The court held the order functioned as a motion to suppress and was broad enough to preclude further prosecution.
Did Miranda warnings apply to questioning at a sobriety checkpoint?	State: No — checkpoint questioning is like a traffic/Terry stop (brief, public) and not custodial, so Miranda not required.	Brown: Checkpoint detention significantly limits liberty without individualized suspicion; feels not free to leave — triggers Miranda.	No. Under these facts (brief two‑minute stops in a public setting) the stop was not custodial; Miranda warnings were not required.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes warnings for custodial interrogation)
Stansbury v. California, 511 U.S. 318 (1994) (custody inquiry focuses on formal arrest or restraint comparable to arrest)
Berkemer v. McCarty, 468 U.S. 420 (1984) (ordinary traffic stops are seizures but generally not custodial for Miranda purposes)
Pennsylvania v. Bruder, 488 U.S. 9 (1988) (traffic‑stop questioning is not custodial for Miranda)
Phillips v. State, 287 Ga. 560 (2010) (Ga. S. Ct.) (roadside safety checkpoint questioning not custodial)
Com. v. Stewart, 846 A.2d 738 (Pa. Super. Ct.) (2004) (no Miranda required before sobriety testing at roadblock)
White v. State, 772 N.E.2d 408 (Ind. 2002) (defining interrogation for Miranda)
Meredith v. State, 906 N.E.2d 867 (Ind. 2009) (Fourth Amendment seizure does not automatically equal Miranda custody)